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WlLLARD K. TOM Genera l Counsel

LISA D. ROSENTHAL, Bar # 179486 3 KERRY O'BRIEN, Bar # 149264

EV AN ROSE, Bar # 253478 4 Federal Trade Commission

90 I Market Street, Ste. 570 5 San Francisco, CA 94103

(415) 848-5100 (voice) 6 (415) 848-5 184 (fax)

lrosenthal@fic.gov 7 kobrieD@fic.gov

erose@fic.gov 8

Attorneys for Plaintiff 9 Federal Trade Commission

i"l ' .. -03 "'': I') P'l ~ . 1 '1

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UNITED STATES DlSTRlCT COURT NORTHERN DlSTRlCT OF CALIFORNIA

San Jose Division

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FEDERAL TRADE COMMISSION,

Plaintiff,

v.

VlRTUALWORKS, LLC, a li mited liability company, alkJa Virtual Works, flk/a Private Date Finder, also d/b/a EverPrivate Card and Secret Cash Card,

JEROME "JERRY" KLEIN, indi vidually and as an officer ofVlRTUALWORKS, LLC, and

JOSHUA FrNER, individually and as an officer of VIRTUAL WORKS, LLC,

Defendants.

Complaint

COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQIDTABLE RELIEF

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Complaint Page 2 of 11

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges:

1. The FTC brings this action under Section 13(b) of the Federal Trade Commission

Act (“FTC Act”), 15 U.S.C. § 53(b), to obtain permanent injunctive relief, rescission or

reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten

monies, and other equitable relief for Defendants’ acts or practices in violation of Section 5(a) of

the FTC Act, 15 U.S.C. § 45(a).

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a),

and 1345, and 15 U.S.C. §§ 45(a) and 53(b).

3. Venue is proper in this District under 28 U.S.C. §§ 1391(b) and (c), and 15 U.S.C.

§ 53(b).

INTRADISTRICT ASSIGNMENT

4. The primary marketing affiliate of Defendants has its primary place of business in

the County of Santa Clara, and Defendants have transacted business with consumers who reside

in the County of Santa Clara.

PLAINTIFF

5. The FTC is an independent agency of the United States Government created by

statute. 15 U.S.C. §§ 41 58. The FTC is charged, inter alia, with enforcement of Section 5(a)

of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair and deceptive acts or practices in or

affecting commerce.

6. The FTC is authorized to initiate federal district court proceedings, by its own

attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as may be

appropriate in each case, including restitution and disgorgement. 15 U.S.C. § 53(b).

DEFENDANTS

7. Defendant VirtualWorks, LLC (“VirtualWorks”) is a limited liability company

registered in California with its principal place of business at 655 Mystic Way, Laguna Beach,

CA 92651. VirtualWorks transacts or has transacted business in this District and throughout the

United States. At all times material to this Complaint, acting alone or in concert with others,

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Complaint Page 3 of 11

VirtualWorks, directly or through its affiliates, has advertised, marketed, and/or sold prepaid

debit cards to consumers throughout the United States.

8. Defendant Jerome “Jerry” Klein was at all times material to this Complaint the

President and CEO of Defendant VirtualWorks. At all times material to this Complaint, acting

alone or in concert with others, he has formulated, directed, controlled, had the authority to

control, or participated in the acts and practices of VirtualWorks, including the acts and practices

set forth in this Complaint. Defendant Klein, in connection with the matters alleged herein,

transacts or has transacted business in this District and throughout the United States.

9. Defendant Joshua Finer was at all times material to this Complaint the owner,

Vice President, and Chief Technology Officer of Defendant VirtualWorks. At all times material

to this Complaint, acting alone or in concert with others, he has formulated, directed, controlled,

had the authority to control, or participated in the acts and practices of VirtualWorks, including

the acts and practices set forth in this Complaint. Defendant Finer, in connection with the

matters alleged herein, transacts or has transacted business in this District and throughout the

United States.

COMMERCE

10. At all times material to this Complaint, Defendants have maintained a substantial

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act,

15 U.S.C. § 44.

DEFENDANTS’ BUSINESS ACTIVITIES

11. From about September 2006 to about February 2007, Defendants marketed a

MasterCard-brand prepaid debit card, called the Secret Cash Card, for an enrollment fee ranging

from $39.95 to $49.95. From about March 2007 to about August 2007, Defendants marketed a

Visa-brand prepaid debit card, called the EverPrivate Card, for an enrollment fee ranging from

$49.95 to $54.95. Hereinafter, the Secret Cash Card and the EverPrivate Card are referred to

collectively as the EverPrivate Card.

12. The EverPrivate Card was touted as a debit card that could be used to shop online

without anyone else knowing. It came with a zero balance and could be loaded with cash at

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Complaint Page 4 of 11

designated locations.

13. Defendants marketed their EverPrivate Card primarily through marketing

affiliates. These entities marketed the EverPrivate Card and referred customers or potential

customers to Defendants. These affiliates typically displayed an offer for the EverPrivate Card

on websites that market short-term, or “payday,” loan services.

14. During the period in which Defendants marketed the EverPrivate Card, Swish

Marketing, Inc. (“Swish”) was Defendants’ highest yielding marketing affiliate. Swish is

located at 555 Bryant Street, No. 349, Palo Alto, CA 94301.

15. Swish operated numerous payday loan websites that displayed offers for the

EverPrivate Card, including but not limited to the websites containing the webpages attached as

Exhibits A, B, and C.

16. Swish operated numerous websites whose homepages were materially similar to

the one depicted in Exhibit A. These homepages, which featured an application form for a

payday loan, conveyed the general message that the consumer, in completing the application

form, was merely applying for a payday loan, as opposed to purchasing any good or service. For

example, in numerous instances, these homepages contained the following attributes:

a. The headlines on the homepage contained various statements in large, bolded font

about payday loans, such as the available loan amounts and possible uses for the

loan, and contained no reference to the EverPrivate Card or to any product or

service other than the payday loan matching service.

b. The homepage displayed a fillable loan application form that required, among

other things, a consumer’s bank name, bank routing number, and bank account

number.

c. The homepage contained no statement suggesting that there were any charges

associated with submitting the payday loan application.

d. The homepage contained no reference to the EverPrivate Card or to any product

or service other than the payday loan matching service.

e. Below the application form, the homepage displayed a submit button, with a label

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Complaint Page 5 of 11

in bold, prominent type, such as, “Get matched for your payday loan!”

17. In numerous instances, consumers who clicked on the submit button referred to in

Paragraph 16e were taken to a webpage materially similar to the webpage depicted in Exhibit B,

which displayed offers for several products or services unrelated to the loan. The webpage

conveyed that these offers were not linked to the loan application process and could be bypassed

without consequence. For example, in numerous instances, these webpages contained the

following attributes:

a. At the top of the webpage a headline in large, bolded text read, “Before you get

your loan, check out the limited time offers below!”

b. At the bottom of the page, a prominent submit button appeared. It contained

large, bolded text, with a label such as, “Finish matching me with a payday

loan provider!”

c. Sandwiched between the two prominent statements described in Paragraph 17a

and Paragraph 17b, this webpage displayed four boxes arranged in a two-by-two

grid. The grid contained four offers e.g., a credit repair kit, a free color printer,

the EverPrivate Card, and an auto loan quote and each had tiny “Yes” and “No”

option buttons, commonly referred to as “radio buttons.”

d. One of the four boxes displayed an offer for the EverPrivate Card. The

EverPrivate Card offer contained 15 17 lines of fine print disclosures that

appeared below the “Yes”/“No” radio buttons. This text was approximately two-

thirds the size of the bolded text of the headline described in Paragraph 17a and of

the submit button described in Paragraph 17b. The first six sentences of text

touted the features of the EverPrivate Card. The seventh, and second to the last,

sentence of the EverPrivate Card description read, “You hereby authorize

EverPrivate Card [Secret Cash Card] to debit your bank account for the one time

enrollment fee of [$39.95 $54.95].” The fee amount was not highlighted or

otherwise made prominent. The phrase “You hereby authorize EverPrivate Card

[Secret Cash Card]” appeared in all capitals, but shared the same font, color, and

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Complaint Page 6 of 11

prominence as the rest of the fine print disclosures.

g. In numerous instances, three of the four offerings including the first one on the

top left (e.g., credit repair) the “No” radio button was pre-clicked. However,

the EverPrivate Card offer, with no commentary or special notice, was pre-

clicked “Yes.”

18. In numerous instances, consumers clicked on the submit button referred to in

Paragraph 17b without affirmatively clicking the “No” radio button above the EverPrivate Card

offer referred to in Paragraph 17d. In such instances, Swish transferred to Defendants certain

information that those consumers had provided on the loan application form, and that

information was used to debit, or attempt to debit, from those consumers’ bank accounts,

between $39.95 and $54.95. Defendants agreed to pay Swish $13 to $15 for each such

transaction.

19. At least two of Swish’s websites had homepages that were materially similar to

the one depicted in Exhibit C. These homepages characterized the EverPrivate Card as a

“bonus” that comes with the payday loan. For example, in numerous instances, these homepages

contained the following attributes:

a. This statement appeared as a bolded headline claim at the top of the homepage:

“Apply now for a Payday Loan of up to $1500 and a BONUS $2,500 Prepaid

Debit Visa* [MasterCard*].”

b. The word “BONUS” in the headline claim, hereinafter referred to as the “BONUS

headline,” appeared in all capital letters. The BONUS headline was marked with

an asterisk.

c. Below the BONUS headline, the homepage displayed a fillable loan application

form that required, among other things, a consumer’s bank name, bank routing

number, and bank account number.

d. Below the application form, the homepage displayed a submit button with a label

such as, “Activate your Prepaid Debit Visa card [MasterCard] and get

matched for a payday loan!”

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Complaint Page 7 of 11

e. The submit button did not alert consumers to the fact that any information

appeared below the submit button.

f. In numerous instances, consumers were not able to view the entire homepage

without affirmatively scrolling down. In such instances, consumers would have

had to affirmatively scroll down past the submit button to see any information

that appeared below the submit button.

g. There was no statement above the submit button disclosing that consumers would

be charged any fee for the “BONUS” prepaid debit card.

h. Below the submit button, six lines of fine print described the EverPrivate Card

offer (the “card description”). The font size of the text in the card description was

smaller than any other text on the homepage, and approximately three-quarters

the size of the font of the bolded BONUS headline. The text was separated into

two paragraphs, the first containing four lines and the second containing two

lines.

i. The card description did not disclose until the fifth line, in the second paragraph,

that consumers would have to pay an enrollment fee of $39.95 to $54.95 for the

“BONUS” prepaid debit card. That disclosure read, “You hereby authorize

EverPrivate Card [Secret Cash Card] to debit your bank account for the one time

enrollment fee of [$39.95 $54.94].” The fee amount was not highlighted or

otherwise made prominent. The phrase “You hereby authorize EverPrivate Card

[Secret Cash Card]” appeared in all capitals, but shared the same font, color, and

prominence as the rest of the fine print disclosures.

j. The first paragraph of the card description was marked by an asterisk, linking it to

the asterisk that followed the BONUS headline. This first paragraph did not

disclose the enrollment fee. The second paragraph, which was not marked by an

asterisk, was the only place on the webpage that disclosed the enrollment fee.

20. In numerous instances, after consumers clicked on the submit button referred to in

Paragraph 19d, Swish transferred to Defendants certain information that those consumers had

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Complaint Page 8 of 11

provided on the loan application form, and that information was used to debit, or attempt to

debit, from those consumers’ bank accounts, between $39.95 and $54.95. Defendants agreed to

pay Swish $13 to $15 for each such transaction.

21. Defendants provided Swish with the basic text of the EverPrivate Card offer that

appeared on the websites referred to in Paragraphs 15 to 20. Defendants and Swish

communicated and worked together regarding the presentation of the offer on those websites.

Defendants, among other things, corresponded with Swish regarding the presentation of the

offer, recommended that Swish present the offer with a default of “Yes,” previewed certain

webpages before Swish put them online, reviewed certain webpages after they were put online,

disseminated print-outs of certain webpages to third parties, and generally had access to these

publicly available websites.

22. Thousands of consumers who submitted loan applications on the websites

referred to in Paragraphs 15 to 20 incurred a debit of $39.95 to $54.95 for the enrollment fee for

the EverPrivate Card. Many of these consumers also incurred fees and penalties from their

banks because they did not have sufficient funds in their accounts to cover this debit.

23. Throughout the period during which the EverPrivate Card offer appeared on

Swish’s websites, numerous consumers who submitted loan applications on the websites referred

to in Paragraphs 15 to 20, upon learning that Defendants had debited funds from their bank

accounts, complained directly to Defendants that they had not authorized the debit. In addition,

numerous consumers filed similar complaints with Swish, the Better Business Bureau, law

enforcement agencies, banks, and payday lenders during this period. On numerous occasions,

these entities, including Swish, forwarded to Defendants the complaints that they had received.

24. Many of the transactions described in Paragraph 22 were reversed, or “charged

back,” by the consumers’ banks. Defendants had access to and monitored this chargeback data.

VIOLATIONS OF THE FTC ACT

25. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts

or practices in or affecting commerce.”

26. Misrepresentations or deceptive omissions of material fact constitute deceptive

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Complaint Page 9 of 11

acts or practices prohibited by Section 5(a) of the FTC Act.

Count I

27. In numerous instances, Defendants, directly or through affiliates acting on their

behalf and for their benefit, have represented, expressly or by implication, that consumers who

completed an online application and clicked on a button labeled “Finish matching me with a

payday loan provider” were only applying for a payday loan.

28. In numerous instances, Defendants failed to disclose adequately to consumers

who completed an online application and clicked on a button labeled “Finish matching me with a

payday loan provider” that they were also purchasing an EverPrivate Card for a fee, typically in

the amount of $39.95 to $54.95, and that this fee would be debited from their bank accounts.

This additional information would be material to consumers in deciding to accept this offer to be

matched with a payday loan provider.

29. Defendants’ failure to disclose adequately the material information described in

Paragraph 28, above, in light of the representation described in Paragraph 27, above, constitutes

a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count II

30. In numerous instances, Defendants, directly or through affiliates acting on their

behalf and for their benefit, have represented, expressly or by implication, that consumers who

submitted a payday loan application would receive a “BONUS” prepaid card at no charge.

31. In truth and in fact, in numerous instances, consumers who submitted a payday

loan application did not receive a “BONUS” prepaid card at no charge. Consumers had to pay a

fee for the “BONUS” prepaid card, typically in the amount of $39.95 to $54.95, and this fee was

debited from their bank accounts.

32. Therefore, the making of the representation set forth in Paragraph 30 of this

Complaint constitutes a deceptive act or practice in or affecting commerce in violation of

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

CONSUMER INJURY

33. Consumers have suffered and will continue to suffer substantial injury as a result

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Complaint Page 10 of 11

of Defendants’ violations of the FTC Act. In addition, Defendants have been unjustly enriched

as a result of their unlawful acts or practices. Absent injunctive relief by this Court, Defendants

are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest.

THIS COURT’S POWER TO GRANT RELIEF

34. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant

injunctive and such other relief as the Court may deem appropriate to halt and redress violations

of the FTC Act. The Court, in the exercise of its equitable jurisdiction, may award ancillary

relief, including rescission or reformation of contracts, restitution, the refund of monies paid,

disgorgement of ill-gotten monies, and other equitable relief, to prevent and remedy any

violation of any provision of law enforced by the FTC.

PRAYER FOR RELIEF

Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b),

and the Court’s own equitable powers, requests that the Court:

A. Enter a permanent injunction to prevent future violations of the FTC Act by

Defendants;

B. Award such relief as the Court finds necessary to redress injury to consumers

resulting from Defendants’ violations of the FTC Act, including but not limited to rescission or

reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten

monies; and

C. Award Plaintiff the costs of bringing this action, as well as such other and

additional relief as the Court may determine to be just and proper.

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DATED: ~'2009

Complaint

Respectfully submitted,

WILLARD K. TOM General Counsel

JEFFREY A. KLURFELD Regional Director

AD.ROS HAL KERRY O'BRJ N EVAN ROSE Federal Trade Commission 90 I Market Street, Suite 570 San Francisco, CA 94103 (415) 848-5100 (phone) (415) 848-5 I 84 (facsimile)

Attorneys for Plaintiff FEDERAL TRADE COMMISSION

Page 11 of 11

ExhibitA

Exhibit A Page 1 of 2

«» CHRISTIAN FAITIl nNANCIAL

'Mlere do you 1Ml?

Do you rent or own your home?

flow can Wi'> cootKt you?

What;s your _S Iicoose

number?

When's your birth<lay?

What's your S<>CiaI securtty ~,

What ;s your monthly Iocom<! afterlllxes?

When do you get p;Jid ne~t?

Do you MY<! direct deposit?

'Nho ;s your employer?

Employed Since

'NIle,e ;s your job located?

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Address (No P.o ........ J

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Do)'<lU rent or own your 00me?

How can we coot.1CI you?

WIllI! is your _sliceflse ~,

W!>en'syour birthday?

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Who Is your employilr?

Emplo';ed Since

Where is yourjob 10Cllled?

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WIIII! ;s the ""me 01 your blink? 1lDn1 .......,. bonk O<:COI.O>I? Click here

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Exhibit A Page 2 of 2

IS ?'I ....

YourBank:: ~

I: 1~3~Sb?&'1 I: 1~3~SIo?&'1101 II" 10210

ABA or Bank Routing Number

BankAccount Number

Check Number ____ "

YotIr bank's ABA routi"ll number

YotIr bankllCCOUlll number

Relatiooship to yoo -Relatiooship to yoo

'MIat is . p3y03y loan'

How to ',Ie! • p3y03y ".n

1

Payday k>an _ What i. _ diff"r"""" between a ""~ k>an and a ca.h advance? What doe. a ca. h advance k>an co.l?

_ <10 yoo apply for a poy<Ioy k>an? S<mpIe 01"". 10 lI"tbn9 a ca.h advance What ar,,_ requir"ment. for a poy<Ioy k>an? _ ml.d> money can yo .. borrow? _ quickly can yoo lI"I a ca.h advance? _ yoo lI"I approved for a poyd>e<:k k>an? _ oft"" can yoo apply for a poy<Ioy

k>an? _ K>og doe. rt tak" 10 lI"I a k>an approved? What if yoo have poor credit or have IiIed for bankllJl>lCY? Ilo yoo need"""f coII.ot"rai 10 lI"I a poy<Ioy k>an or ca.h advance? What hour. i. thi • • """",, available?

P.yO.y ".n p.yment optrn.s What happen. wilen yoor poy<Ioy k>an i. """? \'>'hot ar" _ repayment option.? C_ yoo lI"I_ incr""." on yoor current poy<Ioy loan? What if yoo want 10 pay down yoor loan over time? What happen. ~ yoo <10 not mak" a payment on yoor """ <lot,,? .... ft"r yoo pay back yoor poy<Ioy k>an how K>og <10 yoo have 10 wait ...ru. yoo can receive a new ca.h advance? Loan payment calctMtor

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Yourbank' s ABA rOlJli"ll roJmber

Your bank account...".,,~

WIr.t is. ~.ymy i<>a"? Pay<Soy loan defjnj-. What i. the difference ""_. payday loan and _ Q.h advance? What

doe. a ~." advance loan co"?

JIow do yor.r apply lor-. ~ loan? Si...,..., .. .". to getting. cuh adv.....,., What .re the

require""""" lor-. paydoy loan? JIow much money am you borrow? JIow quirckly.,., yor.r 11"1 a c,aoh advance? 'fflII you II"I-w~ lor a paycl>eck loan? JIow ott.,., can yor.r apply lor a payday loan? !low K>ng doe. it take to 9"I_1oan approved? What il yor.r """" poor credit or I>ove!>led lor _ruptcy1 Do yor.r need any co!~~raI to 11"1 a payday loan or u"", advance? What hour. i. thio .eMceavailabje?

Poyd.y 10." ~ymor>t ~pI""," What '-no when yor.rr paydoy loan i. due? lV"at are"'" r"l'OYmem op-..? Can yor.r 11"1 an increa.e on yor.rr curreflt pay<Say loan? What II yor.r want to pay down yor.rr loan over time? What hoppen" if you do not IThlIk .. a paymeflt on yor.rr due dote? Aft"r yor.r pay bock yor.rr poydoy loan 00w long do yor.r hro"" to wait ..mil yor.r can reeeive _ .....w ~.h advance? loan proyrnem calculator

P.yd.yb .... ~

ExhibitB

Exhibit B

Before you get your loan, check out the limited time offers below!

mprove Your Credit core

(jIGe! a $2,500 Visa Card Ig. y"C N,

wa nt C Credit to repair m y redit report .

BM v:~~~ro" roc. ",~ isaA® Prepa id Card - NO REDIT CHECK.

U visaA® Prepaid Card with y accepting this o lTer I authorize ~ verPrivate is the only way to shop eademy Credit to use the same nline without anyone else knowing.

"fun,,"(ion that I provided ca.-lie.. USI load the card with cash and make creby authorize Academy to debit my ~ urchases anonymously. NO credit

';;:;-;:';'0000=>'::': ':;'0' "'"'-,"",,.m:':',,re:,;,:, .,re,""","; ,(·- J beck, NO link 10 personal credit

~ setup fee 0($97.00, Academy Credit 'nfonnation, NO bill mai led. INSTANT ill continue working on my case for a PPROVAl! It's the perfect solution if oothly fee of549.95 unti l cancellation. ou want to protect your privacy. Check agree that as soon as my initial fee is Yes" and you will receive your VisaAoJ) 'ithdrawn Academy Credit will pull my repaid Card including lifetime free redit report and begin disput ing the cess to EverPrivate Card privacy tools naccurnte, erroneous, untimely and 0 protect your identity. YOU HEREBY nverifiable items therein. I also UTHORIZE EVERPRIVATE CARD cknowledge that I have read the 0 debit your bank account for the one

r tat m n ali n ime enrollment fee of$54.95. See and 2ive my Digital Sjgnature

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agree that as.lOOn as my initial fee is ' thdtawn Academy Credit will pull my

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want a FREE Auto Loan Quott.

et a fllSt, FREE. 1'10 obligation quote for auto loan whether you need a used t:n a newest. All emlil welcome. By

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ExhibitC

Exhibit C Page 1 of 2

• WI1.t is p ur name? First Name Last Name

, Wl1 ere do yoo live? Address City (II<> P.o. _ os)

State S!Oec! St.le &1 , Do you ,mj 0< own your home? Re nt 0 ~ 0 , How can we """tad you? Ema il Address ex. pato5@.oI.com

Hom e Phone

Ce ll Ph",," , Wh.rs yeur drivers license Ucens.1/ Issu ing State numbe;?

• Wh en's p ur birthday? I U<>nlt\ '" II p,,,y '" II Ylt~ 21 , Wl1ars yeur sod," security

number? -

step 2: 1nIomIIIlIooAbw1 Y<u Job

, How ofte n do you get pa id?

, How mum a mootll do you eam aftertaxe, ?

, WIl en do you get paid next? ISeji vIBI2001 8J ~ CI;<" b l[l l~ I II I<l l l n d ", , Do you have direct deposit? S*ct How YO" Recer.e Yo", P'YcMC<

, WT10 is your emp loyer?

• Emp loyed s ince

, WIl er. is your job located? Stat. [1-~-;;"'""''"C:=''l. 1 Zip Code

• WI1ars ycur employe(s phone number? •

~~ ---

51"" J: Your BanllIOg I"I0 .... non

1 Your b.n<s name

2 Your ban<s phone number · 1

3 8ankCh,d<

, What is p ur name? firntName Last Name

, Wh ere do yoo IM!? Address {No p a _ l

St.te Sdod stat. a , Do yoo ,mj or own your hom e? Rent ® ~ 0 , How can Wi! cOI1I.d Y<>U? Email Address ... pato5@ao Lcom

Home Ph""e

Ce ll Ph",," , Whaf. Y(I)r cIrMl(s li cense Ucens." Issuin~ State numben , When"' p ur birthday? IU<IfII!\ "' 11 ~Y il lY- 1£1 , W11ars yeur s<>dal security number?

-S1ep 2: ~_ Your JaIl

, How onen do you ~et pald?

, How mu'" • montll do you .3m aftertax., ?

, WI1en 60 yoo ~et paid next?

, Do you hiM! direct depos it?

, Who is)'OOf eml>o)'<lr?

, Em," oyeil since

, Wher. Is yo ur io ~ IOCOited? Cit, State- [1-~-;;""""C:=''''1 Zi? Code

• WI1afs )'C ur emp loye(s phone number? •

--------StI!IIl Your~-""'"

1 YO<lf ban( s name

:!. Your ban <s phone number:

3 8anI; C~ .(j;

Exhibit C Page 2 of 2

l OUWXUUi I!H_St I_I.-a , lltS

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YourBank:: ~

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$ ..... ' ...

AlIA o'!;.:::L Book Routing Numb ....

L Check Numb .... ___ ---'

4 Your bank's ABA rooli ng num ber:

5 Your bank account number

6 Accoo nt type

~ shOY ld be on fy 9 d; ~ i ts

--------- ---------I tnt Step: Yo..- Refl!f«lCes

1 Name

2 Relati onship layoy

3 Phone Number:

1 tlame

2 Relati onship layoy vi 3 Phooe Number:

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EI !rECURE

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1 tlame:

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3 Phon~ !lumber

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2 Relabonshil> 10 "'"

3 Phooe !lumbe<:

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